Defamation and Emotional Distress Claims in Byrnes Bankruptcy Case

In the United States Bankruptcy Court for the District of New Mexico, the case of Byrnes v. Byrnes involves Sylvia Marie Byrnes as the debtor and Barry J. Byrnes as the plaintiff. This case revolves around two tort claims: defamation and intentional infliction of emotional distress (IIED). The court has been tasked with determining whether these claims fall within its jurisdiction and how they should proceed.

Jurisdiction and Claims

Barry Byrnes, who is representing himself, filed claims against Sylvia Byrnes, alleging defamation and IIED. Although the plaintiff did not consent to the bankruptcy court hearing these claims, a motion was filed to withdraw the reference for trial. The court, however, recommended that the reference for both claims should not be withdrawn.

The court carefully examined the defamation claim and determined that it does not qualify as a personal injury tort, which suggested that the IIED claim might also face dismissal or summary consideration. The court ultimately decided not to remand the claims, opting instead to proceed with the trial in Las Cruces, New Mexico.

Background and Court Proceedings

Sylvia Byrnes filed for Chapter 7 bankruptcy on October 30, 2020, with representation from R. Trey Arvizu III and Mark Lee Pickett. Following the bankruptcy filing, Barry Byrnes removed the claims to the bankruptcy court and filed additional claims separately. These proceedings were subsequently consolidated, and the plaintiff was ordered to submit an amended complaint.

In the amended complaint, Barry Byrnes included two counts: one for defamation and IIED, and another related to domestic support obligations. While the defendant responded to the defamation and IIED claims, she moved to dismiss the count related to domestic support obligations. On July 2, 2021, the court granted the defendant's motion to dismiss this second count, leaving only the defamation and IIED claims for trial.

Barry Byrnes accused Sylvia Byrnes of making false and malicious statements to the police and in a petition for an order of protection. The court decided to try these claims in Las Cruces unless the District Court decided otherwise on the Reference Withdrawal Motion.

Legal Interpretation and Court Ruling

In its decision, the court explored the distinction between "personal injury torts" and other tort claims within the context of bankruptcy jurisdiction. The court referenced various legal interpretations, including narrow and broad views, regarding what constitutes a personal injury tort. It ultimately leaned towards a narrow interpretation, finding that the defamation claim did not meet the criteria to be classified as such.

As a result of this interpretation, the court decided that the defamation and IIED claims could remain within the jurisdiction of the bankruptcy court. The court also noted that the IIED claim, while remaining under its jurisdiction, might still face dismissal or summary disposition due to its connection with the defamation claim.

The court concluded that the defamation and IIED claims would proceed to trial in the Bankruptcy Court for the District of New Mexico. It recommended against withdrawing the reference for either of these claims, ensuring that the case remains under its jurisdiction. The court emphasized its interpretation that the defamation claim does not constitute a personal injury tort, thereby solidifying its decision to retain the claims for trial within the bankruptcy court.